ML100610012

Electronic Transmission, Draft Request for Additional Information Regarding License Amendment Request to Relocate Surveillance Frequencies to a Licensee Controlled Document

ML100610012
Person / Time
Site:	Oyster Creek
Issue date:	03/03/2010
From:	Geoffrey Miller Plant Licensing Branch 1
To:	Chernoff H Plant Licensing Branch 1
Miller G, NRR/DORL, 415-2481
References
Download: ML100610012 (4)

Text

March 3, 2010 MEMORANDUM TO: Harold K. Chernoff, Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: G. Edward Miller, Project Manager /ra/

Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

OYSTER CREEK NUCLEAR GENERATING STATION - ELECTRONIC TRANSMISSION, DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO RELOCATE SURVEILLANCE FREQUENCIES TO A LICENSEE CONTROLLED DOCUMENT The attached draft request for additional information (RAI) was transmitted by electronic transmission on March 3, 2010 to Mr. Glenn Stewart, at Exelon Generation Company, LLC (Exelon, the licensee). This draft RAI was transmitted to facilitate the technical review being conducted by the Nuclear Regulatory Commission (NRC) staff and to support a conference call with Exelon in order to clarify the licensees amendment request dated October 30, 2009 (Agencywide Documents Access and Management System Accession No. ML093060126), to relocate selected Surveillance Requirement frequencies to a licensee controlled document. The draft questions were sent to ensure that they were understandable, the regulatory basis was clear, and to determine if the information was previously docketed. Additionally, review of the draft RAI would allow Exelon to evaluate and agree upon a schedule to respond to the RAI.

This memorandum and the attachment do not represent an NRC staff position.

Docket Nos. 50-219

Enclosure:

As stated

ML100610012 *By memorandum LPL1-2/PM APLA/BC NAME GEMiller DHarrison*

DATE 3/3/10 2/16/10 DRAFT REQUEST FOR ADDITIONAL INFORMATION OYSTER CREEK NUCLEAR GENERATING STATION LICENSE AMENDMENT REQUEST RELOCATION OF SURVEILLANCE REQUIREMENT FREQUENCIES DOCKET NO. 50-219 By letter dated October 30, 2009 (Agencywide Document Access and Management System Accession No. ML093060126), Exelon Generation Company (Exelon or the licensee) requested an amendment to the Technical Specifications (TSs) for the Oyster Creek Nuclear Generating Station (Oyster Creek). Specifically, the requested amendment would relocate selected Surveillance Requirement frequencies to a licensee controlled document. To complete its review, the Nuclear Regulatory Commission (NRC) staff requests responses to the following request for additional information.

1. The license amendment request (LAR) proposes to modify Surveillance Requirement (SR) 4.2.C.3 including the removal of the phrase for at least 20 control rods The modification or deletion of the number of control rods to be tested during performance of the SR was not considered as a part of the model TS change or in the model Safety Evaluation. Provide a justification for why allowing relocation, to the Surveillance Frequency Control Program (SFCP), of the number of control rods to be tested is acceptable. Alternatively, the proposed TS pages may be revised to retain the subject phrase.

2. The NRC staff notes that SR 4.5.F.b.(4) is included in the cross reference table (Attachment 4) included in the LAR, however, the marked-up TSs provided to not propose to relocate the frequency for performing the drywell to suppression chamber leak rate SR. Clarify if retaining this frequency in the TSs is intentional or, if not, provide a revised mark-up for TS page 4.5-4.

3. The proposed revision to SR 4.13 proposes to delete Table 4.13-1 entirely while relocating applicable information from its footnotes to the main part of SR 4.13. The proposed modification to other SR tables (e.g., SR 4.15 and Table 4.15-2). While either method of implementing the change may be acceptable, please clarify the lack of consistency in implementing the proposed amendment.

4. Attachment 2 of the LAR, Table 2-1, Gap #1 justifies mission times exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for loss of decay heat removal sequences as current approach is judged to be reasonable for long term scenarios Given that, for assessing potential risk impact, assuming longer mission times generally increase conservatism by increasing the assumed failure probability of components, provide additional justification as to why this is an acceptable conclusion.

Enclosure

5. Attachment 2 of the LAR, Table 2-1, Gap #3 and Gap #4 justify the current component failure modes only by stating it is judged to include proper treatment Provide additional justification to support this conclusion.

6. Attachment 2 of the LAR, Table 2-1, Gap #8 identifies failure to consider the quality of the plant procedures, administrative controls, and human-machine interface for both pre-and post-initiator human actions. The current status, as listed in the table, is listed as open with a possible upgrade for pre-initiator actions.

a. Provide a discussion of what, if any, possible upgrades are being considered for post-initiator actions.

b. The Importance to Application column identifies that this gap would be addressed by sensitivities per NEI 04-10 if applicable to the specific STI evaluation. Provide an assessment of how utilization of NEI 04-10 adequately mitigates this gap.

7. Attachment 2 of the LAR, Table 2-1, Gap #9, Gap #10, Gap #11, and Gap #12 justify that estimating relevant plant data (i.e., demands and standby time) rather than determining them from actual plant data is sufficient. Estimating data is consistent with capability category I only. Justify why estimating this data is an acceptable approach to resolving the gaps.

8. Attachment 2 of the LAR, Table 2-1, Gap #10 states that the system engineer estimate of demand data is adequate for the PRA, however, Gap #13 states that system engineer experience level is inadequate to obtain insights on maintenance unavailability.

Describe how, as described in the LAR, system engineer experience is adequate to resolve Gap #10 but not Gap #13. Alternately, provide another justification for the resolution of Gap #10 that does not utilize system engineer experience.

9. Attachment 2 of the LAR, Table 2-1, Gap #14 identifies a deficiency in the flood area definitions which, if corrected might introduce new flood initiators, but further states that significant flood scenarios and propagation paths are already appropriately modeled.

Provide the basis for this conclusion regarding significant flood scenarios. Further describe any conclusions regarding the impact of this deficiency documented by the August 2008 focused scope peer review for internal flooding.